Honest Broker

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Policy No.: 8015
Effective Date: DRAFT
Revised Date:
Reviewed Date:

Honest Broker

Policy

UNMC Affiliated Covered Entity (ACE) shall implement an “honest broker” program to ensure compliance with the HIPAA Privacy rules and requirements pertaining to the use and disclosure of protected health information (PHI) and de-identification of PHI used for research and Healthcare Operations as well as any applicable related state laws that are not preempted by HIPAA.

Purpose

The purpose of the Honest Broker Policy is to establish standard operating procedures for de-identification of PHI for the purpose of safely and securely linking together or sharing clinical data to support research in compliance with HIPAA and IRB requirements.

Definitions

Affiliated Covered Entity (ACE)

Legally separate covered entities have designated themselves as a single covered entity for the purpose of HIPAA Compliance. Current UNMC ACE members are: UNMC, Nebraska Medicine, UNMC Physicians, University Dental Associates, Bellevue Medical Center, and Nebraska Pediatric Practice, Inc. ACE membership may change from time to time. The Notice of Privacy Practices lists current ACE members.

Business Associate

A person or entity, other than a member of the workforce of a covered entity, who performs functions on behalf of a covered entity per 45 CFR 160 is a business associate.

De-identification

De-identification refers to removal of all18 of the HIPAA identifiers or any other identifiers which would allow the reasonable possibility for investigators or others to identify patients directly or indirectly to prevent re-identification of patients.

Additional Information

• Contact the Compliance Officer
• UNMC Policy No. 1098, Corrective/Disciplinary_Action
• UNMC Procedures No. 1098, Corrective and Disciplinary Action
• Corrective and Disciplinary Action Form.
  
• UNMC Policy No. 1006, Employee Separation
• UNMC Policy No. 1020, Employee Grievance Process
• International Project Questionnaire

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